Archive

FINCEN CLARIFIES CTR SOLE PROPRIETOR AND DBA REPORTING REQUIREMENTS

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued ruling (FIN-2020-R001) on currency transaction reporting (CTR) requirements, FinCEN Form 112, involving sole proprietorships and legal entities operating under Doing Business As (DBA) names. The changes will be effective April 6, 2020, September 1 for E-Filing batch filers. This ruling replaces FIN-2006-R003 and FIN-2008-R001. For sole proprietorships the ruling states: Complete a single Part I “Person Involved in Transaction” section with the individual owner’s […]

2020 HMDA GUIDE

On February 12, 2020 the Federal Financial Institutions Examination Council (FFIEC) published its 2020 version of A Guide to HMDA Reporting – Getting It Right. The Guide, which has been published since 1998, provides a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data. The 2020 version is updated to include information from the final rule published by the CFPB in October 2019. Primarily, the 2020 Guide […]

CFPB REGULATORY STATUS CHECK

On February 6, 2020 Kathleen Kraninger presented the Consumer Financial Protection Bureau’s (CFPB’s) Fall 2019 Semi-Annual Report to Congress, covering the period from .April 1, 2019, to September 30, 2019. The Report provides updates on a number of current regulatory efforts including, but not limited to: Payday, Vehicle Title, and Certain High-Cost Installment loans In February 2019, the CFPB released Notices of Proposed Rulemaking (NPRM) on the 2017 Payday, Vehicle Title, and Certain High-Cost Installment […]